Privacy Policy

How we take care of your privacy

Last updated: May 1th, 2020
Introduction

Privacy essential for you and for us. We understand that and will be as transparent as possible when it comes to your use of the service.

Talentroo is an online portal where you can create a professional profile which can be found by members/clients looking to hire.
We value privacy as well as you, and we only collect the data that is needed to run the website and to provide the services included.

The information you provide to us is yours and yours only. Selling and redistributing your information is not our intention. You are in full control throughout the usage of the website, and at any time you can ask us to delete your info.

For any questions or worries you must have, do not hesitate to get in touch with us on email.

Table of contents

About this page

On here we will explain and inform you about our privacy practices. Our goal is to clearly communicate to you our rules in regard to how we collect, use and disclose personal data when you use Talentroo and the choices you have with that data.In general, we will only use your data to provide the service and to improve it.

When you sign up to use Talentroo you have to tick a check a box to say that you have agreed to the collection and use of this information in accordance with this policy. That is your contract with us, and we deem to ensure that we are transparent with what we do with your data. Also, unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.
Some key definitions

We have tried to simplify the language as much as possible, so this policy is easily understandable. However, there are some technical words that is useful to provide a definition for as they are important for the total understanding of the policy.

Data Controller. Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.

Data Processor. Data Processor means any natural or legal person who processes the data on behalf of the Data Controller. (for example, third parties connected to the website)We may use the services of various data processors in order to process your data more effectively.

Data Subject. Data Subject is any living individual who is using our Service and is the subject of Personal Data. You are the data subject here.

Personal Data. Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

Cookies. Cookies are small files (tokens) stored on your device (computer or mobile device).

Usage Data. Usage Data is data collected automatically generated when you visit the website through e.g analytics tools such as Google analytics. (for example, from when you enter the website and how much time you spend on it).
What personal data do we collect?

To be clear, we do collect some data for the purposes of providing the service you expect from Talentroo and in order to improve the website user experience.

In terms of what is considered Personal Data, the only data we need to for you to have member profile on Talentroo is;

- Email address
- Your name

We You must use your real name to use Talentroo. Creating an account with false information is a violation of our terms. We also need email where we can reach you to be able to communicate with you when needed.

If you are a member looking for talents, your name and email is not visible anywhere on the website and is only stored on ours or third-party servers connected with our service.

If you are a talent with a talentroo profile your email and will be seen and can be used by members looking to hire talents.
What usage data do we collect?

When you visit the website and subsequently navigate and use the website, we will gather some usage information. This is information we need to understand how and if the website works, to protect it from spam and strange behaviour. This is to protect the data you provide to create your online profile.

To give you an idea, when you visit the website, we may collect certain information automatically, including, but not limited to;

- the type of device you use
- your device unique ID
- the IP address of your device
- your operating system
- the type of Internet browser you use
- unique device identifiers
- other diagnostic data.

This data cannot be linked to you as a person. It is technical data and all the data is bundled up so we will only see numbers (for example, how many people visit the website during a day).
What other data do we collect?

When we are creating your talent profile we ask you to provide information about yourselves. This is optional, and we ask you to not add any information that is personal to you and can be used to identify you in ways you don`t feel comfortable. We do not ask for your personal address or phone-number.

The information we ask you to provide that is not regarded as Personal Data is;

- Your professional title
- Your profession
- Your skills within that profession
- Your work availability
- What is you base region that you spend the most time
- Links to your social media sites and other websites you have
- A section for you to write about your work/project achievements

In addition, we ask you to provide us with data that is considered Personal Data;

- Your current location
- Your nationality

In addition, we ask you to upload your CV. The CV is only available to download for members with a membership. We are not responsible for the information you have in your CV or who downloads it, or what they do with your information.
How we deal with the recorded interviews.

If you become a talent listed on our profile looking for a job you will conduct an interview with us.

We are recording the interviews through the online service Google Meet, and the video is stored only locally device of the person conducting the interview and on the google drive account connected to Talentroo.

We do not ask any specific personal questions in the interview, but we take no responsibility if you say something that is private and personal to you. Also it is voluntary if you want to show your face, as audio only is permitted, but we do not recommend to not use audio only.

All Talentroo interviewers have signed a Data Processor agreement where they agree to send the recording to the Data Controller and thereafter delete the recording.

All recordings are uploaded on a private hidden Vimeo account used by Talentroo. The videos and its content are not public.

The recordings are only visible to clients with a membership on Talentroo and is not available outside the platform. We do not sell, redistribute or use the recordings in any other way.

If you have any concerns about the recordings do not hesitate to send us an email.
Location data.

We have some additional location data based on the IP address you use the website. The IP address will not give us an accurate location, just an estimate. This information is used only for analytical purposes and is not stored. This location data can not be connected to you as a person.
Cookies.

No privacy policy without mentioning cookies. As described under definitions, cookies are a small file that is put on your browser to send some information back to the owner of the website and the analytical tools that are connected to it.

When you visit the website, a small cookie is placed on your browser. This cookie will give us information about what you did on the website and is stored until the next time you visit the website again. For example, it can help us now if you stilled are logged in.

We have previously described under Data Usage above what is collect in this cookie.

Some examples of cookies Talentroo use is:

- Session Cookies. We use Session Cookies to operate the website.
- Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
- Security Cookies. We use Security Cookies for security purposes.

In your browser settings you can set the browser to automatically delete all cookies we have placed on your browser after exiting the website. You can also set it to not collect any cookies, however setting this option might break the website, and some functions might not work as intended.

Although, we want to emphasise that we do not collect any information that gives us your identity in these cookies. It is only for analytical purposes only.
How do we use the data we collect?

We process your information for purposes based on legitimate business interests, the fulfilment of our contract with you, compliance with our legal obligations, and/or your consent.

We have already mentioned what we collect, and also tried to explain why we collect what we collect. So, to summarise, here is how we use that data we collect:

We use the information we collect or receive:  

- To facilitate account creation and logon process with your Consent.

- To send you marketing and promotional communications for business purposes and/or with your consent. We and/or our third party partners may use the personal information you send to us for our marketing purposes. You can opt-out of our marketing emails at any time.

- To send administrative information to you for related to your account, our business purposes, and/or for legal reasons. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.

- Fulfil and manage your orders for contractual reasons. We may use your information to fulfil and manage your orders and payments.

- To post testimonials with your consent. We post testimonials on our Site that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and testimonial. If you wish to update, or delete your testimonial, please contact us on email and be sure to include your name, testimonial location, and contact information.

- Deliver targeted advertising to you for our business purposes and/or with your consent. We may use your information to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.

- Administer prize draws and competitions for our business purposes and/or with your consent. We may use your information to administer prize draws and competitions when you elect to participate in competitions.

- Request feedback for our business purposes and/or with your consent. We may use your information to request feedback and to contact you about your use of our Site.

- To protect our Site for business purposes and/or legal reasons.  We may use your information as part of our efforts to keep our Site safe and secure (for example, for fraud monitoring and prevention).

- To enable user-to-user communications with your consent. We may use your information in order to enable user-to-user communications with each user’s consent.

- To enforce our terms, conditions and policies for our business purposes and as legally required.

- To respond to legal requests and prevent harm as legally required. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

- For other business purposes. We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our site, products, services, marketing and your experience.
How we keep your data secure?

We have implemented appropriate technical and organisational security measures designed to protect the security of any personal information we process. The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure.

While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Although we will do our best to protect your personal information, transmission of personal information to and from our Site is at your own risk. You should only access the services within a secure environment.

We have worked with data protection specialists during the development of the website.
How long do we keep your data?

The data we collect, the email, your name, and usage data we will only keep for as long as necessary for the purposes as we have described here in this policy.

Even though we don`t intend it to happen, we might need to keep some data in order to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

Also, we will keep some data for internal analytical purposes. This usage data is only kept for a short time period, unless it is needed to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.
Where is your data located?

When you sign up with your email and name or make a talent profile, in addition to being shared with Talentroo, your data is shared with some third-party providers. These are considered our Data Processors.

Talentroo is located in the EU, so we follow the GDPR.

If you sign up to use this website outside of the country or region where the Data Controller is legally located your data will be transferred – and maintained on – computers and servers located outside your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. If you are located outside the EU and use our website and the services offered, please note that we transfer the data, including Personal Data, to the EU and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

The data controller will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.
Who do we share the data with?

We employ some third-party companies and individuals to facilitate our website. These are Data Processors that provide services on our behalf, and perform services and assist us in analysing how our website is used.

We are not responsible for the safety of any information that you share with third-party providers who advertise, but are not affiliated with, our websites. These third parties have access to your Personal and Usage Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. These third parties are not affiliated with us.

We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy policy. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the site.

You should review the policies of such third parties and contact them directly to respond to your questions.

The third party companies we work or share data with and links to their privacy policy:
Who can ask to see the data?

Under certain very specific circumstances, the Data Controller may be required to disclose your Personal and Usage Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).For some legal requirements the data controller may disclose your Personal Data in the good faith belief that such action is necessary to:

- To comply with a legal obligation.
- To protect and defend the rights or property of the data controller.
- To prevent or investigate possible wrongdoing in connection with the usage of the app.
- To protect the personal safety of users of the app or the public
- To protect against legal liability
Your data protection rights.

As we have stated earlier, we value your privacy, but you also have a right to privacy. We are making every effort to follow all applicable data protection policies and regulations. Among the strongest of these is the GDPR – The general data protection regulation. If you are from the EU or European Economic Area (EEA), the Data Controller’s basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.The Data Controller may process your Personal Data because:

- We need to perform a contract with you.
- You have given us permission to do so
- The processing is in our legitimate interests and it is not overridden by your rights
- To comply with the lawIn addition, you will under the GDPR have other specific rights.

The data controller aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data. In certain circumstances, you have the following data protection rights:

- The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly by sending us an email.

- The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.

- The right to object. You have the right to object to our processing of your Personal Data.

- The right of restriction. You have the right to request that we restrict the processing of your personal information.

- The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.

- The right to withdraw consent. You also have the right to withdraw your consent at any time where Moa Solutions OU relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the EU or European Economic Area (EEA).

If you are a user from outside the EU, please contact us for details how to complain.
Children's Privacy

Our Service does not address anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us.

If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our and third-party servers.
Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on the website prior to the change becoming effective and update the "effective date" at the top of this Privacy Policy.You are advised to review this Privacy Policy periodically for any changes.

Changes to this Privacy Policy are effective when they are posted on this page.
Who is the Data Controller?

The owner and creator of Talentroo is:

Moa Solutions OU
Sepapaja 6
15551
Tallinn, Estonia.
How can you contact us?

If you have any questions about this Privacy Policy, please contact us on email.

Data Protection Officer - Privacynow.net